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employers. The record does not indicate that petitioner
requested or inquired about a Form W-4 from DBMA.
Based on the record before us, the facts are consistent with
independent contractor status.
8. Conclusion
In the matter before us, although one factor might indicate
an employer-employee relationship, the vast majority suggest that
petitioner was an independent contractor of DBMA. Having weighed
the evidence and considered the totality of the circumstances, we
conclude that petitioner was an independent contractor of DBMA.
As a result, he is responsible for self-employment tax for 2003.
In reaching our holding herein, we have considered all
arguments made by the parties, and to the extent not mentioned
above, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007